Another bucket of new resources can come from generation replacement service, which uses the grid interconnections of shuttering power plants to connect new resources. Xcel Energy, a Minnesota utility within MISO, has taken advantage of this process, building a large solar-plus-storage project near the site of a retiring coal power plant.
Taken together, these opportunities add up to more than enough new grid capacity to meet the new power demand MISO forecasts into the end of the decade, according to Brattle’s report.
“Significant new resources will in fact be necessary,” Hagerty said. “Thankfully there are a lot of resources that can be developed and are being developed through existing interconnection processes that can serve” MISO’s future needs.
Why ERAS could make things worse
Not only is the ERAS proposal unnecessary, Hagerty said, but it won’t help MISO achieve its goals. In fact, it’s likely to make things worse.
That’s because the proposal ignores a key lever for reducing interconnection logjams: Making better use of existing grid capacity.
Grid capacity is scarce in the U.S. Regulators and grid operators are pushing to fix that by building more transmission lines, and MISO specifically is undertaking one of the country’s most ambitious transmission buildouts. But new transmission can take up to a decade to build, meaning that for now grid operators and utilities have to make better use of their existing grid capacity.
MISO is also improving its interconnection processes. For example, MISO has been using software tools to streamline complex grid studies — an innovation that has won accolades from FERC. That can help bring more projects online faster within existing capacity limits.
But MISO’s ERAS proposal lacks requirements to coordinate the selection of fast-tracked power plants with an analysis of where the MISO grid has extra “headroom” to accommodate them. That creates the risk that ERAS projects will be able to move ahead even if MISO later determines that they will cause even more grid congestion on an already congested system.
That, in turn, could force MISO to reject grid interconnection requests from projects that have been patiently waiting for years for a shot at being considered — or force them to absorb multi-million-dollar grid-upgrade costs to get online. That “poses a significant risk of imposing higher interconnection costs and slower interconnection timelines on MISO’s existing interconnection customers,” Sierra Club and other environmental groups said in a protest filed with FERC.
Nor does ERAS force projects to be built quickly enough to solve the grid problems it was ostensibly designed to solve, Sierra Club’s Wannier said. While the plan does set a three-year deadline to connect to the grid, it also allows utilities to seek a further three-year extension, which means they might not start generating power before 2031 — years after MISO’s stated end-of-decade reliability concerns.
And even if utilities wanted to build these power plants ASAP, it’s not clear they would be able to. Recent reports indicate that manufacturers of power-plant gas turbines, such as GE Vernova, Siemens, and Mitsubishi, are fully booked through the end of the decade, with no excess production capacity available.
In the meantime, those ERAS projects would be clogging up grid capacity that other resources could use, including solar, wind, and batteries, which can be built much faster.
That could turn ERAS into a “second, unmanageable queue that would paralyze the MISO interconnection process,” clean energy developers including Clearway Energy Group, EDF Renewables, Enel Green Power North America, and NextEra stated in a protest filed with FERC.
Similar concerns are dogging other proposals to fast-track gas-fired power plants to solve grid challenges in PJM Interconnection, which manages the transmission grid and energy markets for a region including all or part of 13 states and Washington, D.C. But critics of MISO’s ERAS proposal say that it’s even more problematic than the PJM proposal, which FERC approved in February.
That’s because PJM’s fast-track regime, dubbed its Reliability Resource Initiative, is a “one-time deal,” Wannier said, allowing up to 50 projects to seek expedited interconnection in a single window of applications. MISO’s ERAS, by contrast, will allow utilities to propose new power plants for the fast-track process four times per year for the next three and a half years, and could be extended past that deadline, he said.
“MISO has limited staff time and engineering capabilities,” he said. “The more time they commit to the ERAS process, the more time the rest of the projects in the queue will be delayed.”
State regulators must approve any ERAS proposal, which could help prevent crowding the queue with projects that are unlikely to be built in the near term. But as Wannier pointed out, regulators will face pressure to back proposals that let utilities off the hook for the costs of upgrading the grid to support the power plants they’re planning. While such lenience could reduce the costs that are passed through to utility customers, that dynamic may clog queues and raise power costs across MISO at large.
“The way that MISO has structured it, utilities are set up to be free riders on the transmission system — which creates an incentive for utilities to put as many projects as they can into this ERAS process,” Wannier said.
Breaking the competitive compact
MISO spokesperson Brandon Morris said that the ERAS process was developed “collaboratively with state regulators in the MISO footprint” to meet the “urgent need to move projects through the interconnection queue, including projects needed due to accelerating load growth driven by data centers.”
“We’re focused on completing these projects as quickly as possible while continuing to make improvements to interconnection queue processes,” Morris said.
But Morris declined to comment on concerns that eight former FERC commissioners — both Democrats and Republicans — raised in an April letter to the federal agency. They wrote that the ERAS plan “runs counter to everything FERC has tried to do to preserve open access since the Commission’s landmark issuance of Order No. 888.”
Order No. 888 refers to rules FERC created in 1996, which require traditional utilities that own and operate their own power plants and serve customers in their territories to allow non-utility parties to connect new grid resources. That rule was necessary because regulated utilities earn a guaranteed profit on every dollar they spend building new power plants, and thus have a built-in incentive to fight third-party power plants that compete with them.
This incentive lies at the heart of many of the conflicts between state-regulated utilities and independent energy project developers — and it’s at the center of the ERAS debate as well. The former FERC commissioners warned that ERAS’ preferential treatment for utility power-plant proposals will “undermine competition in MISO leading to higher costs for customers,” by erecting “unduly discriminatory barriers” against projects that aren’t sponsored by utilities.
While it’s theoretically possible for third-party developers to propose ERAS projects, the reality of the situation is Kafkaesque. Developers need to secure customers for their power before getting approval to interconnect. But every independent power project needs an interconnection agreement before it can close power deals, making that option “unworkable,” the former commissioners wrote.
“It has been nearly 30 years since FERC first planted the flag of open access when the Commission issued Order No. 888,” the commissioners wrote. “We have come too far to reverse course now.”
